Procedure for the Compliance Hotline
Introduction
Novo Nordisk has made it possible for employees and external stakeholders to report suspected misconduct in a secure and confidential way. The Compliance Hotline is available by both phone and online via the Hotline available through novonordisk.com or through the Novo Nordisk Intraweb frontpage.
Why a Compliance Hotline
The Compliance Hotline provides two main benefits: It permits Novo Nordisk to learn of wrongdoing and to take actions to stop it, and it permits employees and external stakeholders to report concerns about wrongdoing by employees or third parties acting on behalf of Novo Nordisk.
When someone violates a law or internal procedures, he or she places Novo Nordisk, and possibly other colleagues, at risk. The sooner that wrongdoing stops, the better it is for everyone involved.
A growing number of global companies are establishing similar reporting systems, as it allows them to learn about wrongdoing quickly and to resolve matters quickly. Such systems give an additional reporting mechanism to persons who might otherwise hesitate or fail to report a matter internally. Some employees may fear that they will place their jobs at risk by reporting a concern internally, e.g. if they report wrongdoing by an immediate manager. Others may not feel comfortable making reports to the immediate manager for cultural reasons.
How it works
The Compliance Hotline is hosted by Global Compliance, a US-based company that supplies reporting systems to many global companies. A person making a report by phone will speak with a Global Compliance operator, who will request information and then send a written summary to the Audit Committee Secretariat and the Audit Committee. The operator will include any contact details the reporter wishes to provide. Someone making an online report will write a message and can upload documents into the system. Afterwards, Global Compliance will send those materials to the Audit Committee Secretariat and the Audit Committee. The reporter is encouraged to explain the concern in sufficient detail to facilitate an investigation.
Although reporters can choose to be anonymous, we encourage all reporters to identify themselves so we can better investigate the report and maintain contact with the reporter during an investigation.
If you report anonymously, the Audit Committee Secretariat will only be given your report ID number. However, it may be possible that the information you provide is so specific that someone participating in the investigation will be able to identify you. We will always protect your confidentiality to the extent possible in conducting a thorough investigation.
We encourage you to follow-up on your report using the provided PIN number to check the status of your concern, provide additional information or to check whether we have additional questions to better investigate your report. If you give your name, we may contact you with questions, requests for more information, etc., either directly or through the Compliance Hotline.
If you provide your name, we will treat the report as confidential and protect your identity to the extent possible in conducting a thorough investigation. This means, for example, that it may be necessary to reveal your name to an independent investigator for him or her to assess all the information in the specific case. It may also be the case that we are required to provide a law enforcement agency with evidence related to an investigation, which could include your report.
Management of the Compliance Hotline
The Compliance Hotline is managed by the Audit Committee Secretariat and is monitored by the Audit Committee. The Audit Committee has three members elected by the Novo Nordisk Board of Directors among its members.
Investigations
The Audit Committee secretariat will assign investigators for each reported concern.
All concerns related to: Novo Nordisk Way misconduct will be investigated by Novo Nordisk’s internal Facilitators. Financial fraud or business ethics misconduct will be investigated by Novo Nordisk’s Group Internal Audit or the internal legal network.
Quality misconduct will be investigated by Internal Audit in Global Quality. Serious unfair treatment of an individual employee by the direct manager or line organisation will be investigated by the Ombudsman in Novo Nordisk.
All concerns may also be investigated by an independent external investigator if needed.
Investigations will be thorough, objective and prompt, taking all relevant facts into account. This includes, if necessary, employee emails, phone and internet records, computers, telephones and other equipment to the extent permitted by relevant personal data regulation. Anyone under investigation will be appropriately informed as required by law.
Employees interviewed or otherwise assisting in any investigation are expected to cooperate fully in investigating the matter, providing accurate information and answering questions honestly and completely.
All information involved in an investigation will be stored and subsequently destroyed according to applicable laws.
If an investigation confirms the concern, appropriate administrative or disciplinary actions will be taken.
Misuse of the Compliance Hotline or retaliation
By nature, a reporting system can be abused, e.g. if persons make false accusations or use the system to spread unfounded rumors. Persons who knowingly make false reports or who otherwise abuse the system will face disciplinary action. Thus, it is as important for Novo Nordisk to determine that someone has been wrongly accused of violating a law as it is for the company to take action when someone has violated the law.
Likewise, Novo Nordisk will not tolerate discrimination or retaliation against persons who in good faith make a report or participate in an investigation.
If you believe that you have been retaliated against for reporting or participating in an investigation, you should immediately report such potential retaliation to the Compliance Hotline. All such reports will be investigated confidentially.
Legal rules
The laws of some countries impose specific restrictions on reports, such as what may be reported or whether or not a report is allowed to be submitted anonymously. Such specifications are incorporated into our system.
Concerns that may not be reported through the Compliance Hotline due to the EU restrictions should be directed to the immediate managers. If an employee feels it is impossible to address that issue locally, he or she should escalate it within the unit, e.g. to their local Human Relations contact or local legal counsel.
